Tuesday, September 28, 2021

New vaccine guidance for federal contractors and subs

You knew this was coming because Pres. Biden ordered it a few weeks ago... well, now it's here. Behold, Safer Federal Workforce Task ForceCOVID-19 Workplace Safety: Guidance for Federal Contractors and Subcontractors. In other words, the vaccine mandate for federal contractors. 

If you have federal contractors, then read the whole thing. I'll note some highlights though:

  • All "covered contractor employees" must be fully vaccinated for COVID-19 by December 8, 2021;
  • The requirements will be incorporated into new contracts awarded on or after November 14th (and agencies are encouraged to include the requirements in contracts awarded from October 15th to November 13th);
  • Not official use.
    "Covered contractor employees" has a super-broad definition. It covers full- and part-time. It includes employees who work on - or even in connection with (think, HR, billing, legal review, etc.) - covered contracts. It covers employees who aren't even working on or in connection with federal contracts! - but, only if the employee works at a location controlled by the employer-contractor, and an employee working on (or in connection with) the contract is likely to be present; and
  • The employer must review all of their covered employees' documentation to prove vaccination status:
    • a copy of the record of immunization from a health care provider or pharmacy, 
    • a copy of the COVID-19 Vaccination Record Card (CDC Form MLS-319813_r, published on September 3, 2020), 
    • a copy of medical records documenting the vaccination, 
    • a copy of immunization records from a public health or State immunization information system, or
    • a copy of any other official documentation verifying vaccination with information on the vaccine name, date(s) of administration, and the name of health care professional or clinic site administering vaccine.
    • An attestation without one of the above is not enough.

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